Compliance verification activity type: Field Inspection
Team:
Regulated company: Trans Mountain Pipeline ULC
Operating company: Kinder Morgan Canada Inc
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
TMEP Inspection of Burnaby Terminal
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Regulatory instrument number(s):
Observation 1 - Review of responses to the pre-inspection IR 1 - IR 5
Date & time of visit: 2022-07-04 09:00
Discipline: Integrity Management
Categories:
Facility:
Observations:
Information request (IR) 1 and IR 2 TMEP provided the list of welding procedure datasheet (WPDSs) for tank plates at the Burnaby Terminal (i.e., WPDS Matrix document) TMEP also provided the following WPDSs and related tank welding procedure specifications (WPS) weld map matrix from the list requested above:
Compliance tool used: No compliance tool used
Observation 2 - Day 1
Date & time of visit: 2022-06-28 14:00
TMEP field office at Burnaby Terminal:
Observation 3 - Day 2
Date & time of visit: 2022-06-29 08:00
CER inspectors requested the welding parameters verification report for tank TK97 for review and comparison with the requirements of the TMEP joining program (IR 13). The response was provided on 11 July 2022, then later reviewed. (Refer to Observation "Review of response to IR 13 (TK97 Weld Parameter Verification)"). The NDE requirements for shell plate welding greater than 1" was confirmed to be 100% Phased Array Ultrasound Testing (PAUT) and for plate thicknesses less than 1", random spot check PAUT is performed. Radiographic welding testing was confirmed only for annular plates. All "T" intersection welds were confirmed by TMEP to be 100% PAUT tested.
Observation 4 - Review of responses to IR 9 (Additional information to former responses to IR 1- IR 5)
Additional information was provided at the time of inspection on Day 2, as follows: 1. Regarding welding procedure KE-038 Rev.1 TMEP clarified that the difference in revision numbers found on the TMEP cover sheet and the contractor’s welding procedure specification (WPS) is due to the TMEP Document Control procedure of giving a revision number with each review cycle and submission. TMEP publishes the document submission revision number and the contractor publishes their WPS revision number. TMEP confirmed that the cover sheet is TMEP Document Control Rev.2 and the WPS is the contractor’s Rev.1. No further information was required. 2. Regarding welding procedure KE-052 Rev.0 TMEP confirmed that the cover sheet is TMEP Document Control Rev.2 and the WPS is the contractor’s Rev.0. No further information was required. 3. Regarding welding procedure KIC-1 Rev.3 / KLTP-WPDS-KIC-1 TMEP confirmed the signature on cover page is sufficient. No further information was required. 4. Regarding welding procedure KE-065 Rev.2 TMEP confirmed that the cover sheet is TMEP Document Control Rev.2 and the WPS is the contractor’s Rev.1. CER inspectors noted that CER records on file, show Contractor WPS "Rev 1", not Rev. 2 as shown in the welding procedure datasheet (WPDS) Matrix file. Additional information is required to clarify TMEP's response (IR 28-a) 5. Regarding welding procedure PKS-3 Rev.0 TMEP confirmed that the cover sheet is TMEP Document Control Rev.2 and the WPS is the contractor’s Rev.1. CER inspectors noted that CER records on file show Contractor WPS Rev. 1, while TMEP refers to "contractor" Rev. 0.Additional information is required to clarify TMEP's response (IR 28-b) 6. Regarding welding procedure KE-068 Rev.0 / KLTP-WPDS-KE-068 a. On 11 July 2022, TMEP clarified that the WPS Revision "R1A" referenced in WPDS was a typo error and that KE-068 Rev. 0 is the correct revision as published on the WPS. b. TMEP confirmed the signature on cover page is sufficient. No further information was required. 7. Regarding Horton CBI WPDS-WPS-E7018-1 TMEP replied that the HCBI's practice of using weldable primer was not aligned with TMEP specifications. HBCI subsequently performed a validation exercise of the WPS using weldable primer to demonstrate that it would not negatively affect the performance of the weld. Validation followed the procedure qualification record (PQR) test requirements of ASME BPVC Sec. IX, and was completed in accordance with the parameters in the approved WPS. The use of weldable primer was accepted, and the WPS was revised to include the validation PQR data as well as the use of weldable primer. TMEP points out that the revision to using weldable primer is not an essential variable change under ASME BPVC Sec IX, and therefore in TMEP's view would not require a Condition 111 filing update to the CER. CER inspectors agree with TMEP's view, and do not require further information on the matter. 8. Regarding Horton CBI WPDS-WPS-EG72T-G a. TMEP replied that the HCBI's practice of using weldable primer was not aligned with TMEP specifications. HBCI subsequently performed a validation exercise of the WPS using weldable primer to demonstrate that it would not negatively affect the performance of the weld. Validation followed the PQR test requirements of ASME BPVC Sec. IX, and was completed in accordance with the parameters in the approved WPS. The use of weldable primer was accepted, and the WPS was revised to include the validation PQR data as well as the use of weldable primer. TMEP points out that the revision to using weldable primer is not an essential variable change under ASME BPVC Sec IX, and therefore in TMEP's view would not require a Condition 111 filing update to the CER. CER inspectors agree with TMEP's view, and do not require further information on the matter. b. TMEP replied that the heat input limits are aligned with the Electrical Characteristics in WPS EG72T-G. However, CER inspectors note that the maximum heat input of 393.8 Kj/ in in the welding parameters of WPDS exceed the maximum heat input of 359 Kj/in in the WPDS notes. Additional information is required to clarify TMEP's response (IR 28-c). 9. Regarding Horton CBI WPDS-WPS-E7024-1 TMEP replied that the HCBI's practice of using weldable primer was not aligned with TMEP specifications. HBCI subsequently performed a validation exercise of the WPS using weldable primer to demonstrate that it would not negatively affect the performance of the weld. Validation followed the PQR test requirements of ASME BPVC Sec. IX, and was completed in accordance with the parameters in the approved WPS. The use of weldable primer was accepted, and the WPS was revised to include the validation PQR data as well as the use of weldable primer. TMEP points out that the revision to using weldable primer is not an essential variable change under ASME BPVC Sec IX, and therefore in TMEP's view would not require a Condition 111 filing update to the CER. CER inspectors agree with TMEP's view, and do not require further information on the matter. 10. Regarding Horton CBI WPDS-WPS-EM12K-860 TMEP replied that the HCBI's practice of using weldable primer was not aligned with TMEP specifications. HBCI subsequently performed a validation exercise of the WPS using weldable primer to demonstrate that it would not negatively affect the performance of the weld. Validation followed the PQR test requirements of ASME BPVC Sec. IX, and was completed in accordance with the parameters in the approved WPS. The use of weldable primer was accepted, and the WPS was revised to include the validation PQR data as well as the use of weldable primer. TMEP points out that the revision to using weldable primer is not an essential variable change under ASME BPVC Sec IX, and therefore in TMEP's view would not require a Condition 111 filing update to the CER. CER inspectors agree with TMEP's view, and do not require further information on the matter.
Observation 5 - Review of response to IR 8 (Tanks welding NCRs)
Date & time of visit: 2022-07-05 11:00
TMEP provided the Non-conformance Reports (NCRs) information regarding tank plate welding requested by CER inspectors on "Day 1". The information included Horton CBI's repair rate statistic by tank which varies from 0.1 % (TK 95) to 2.1% (TK 80) and an overall repair rate of 0.84%. The information also included the list of ten NCRs issued, their status, and corrective actions. Three NCRs (NCR-0229, NCR-0228 and NCR-0096) are still open. TMEP responses state that NCR-0228 and NCR-0229 dispositions have been actioned, and the current status is generating the necessary as-builts. NCR-0096 is related to hard stamping and represents a global NCR affecting multiple tanks and it will be closed when all work is completed. During the inspection, CER inspectors requested from TMEP information regarding the last NCR issued and associated corrective actions. TMEP confirmed that NCR-0229 issued on 20 April 2022, was an arc strike that caused copper inclusion on the floating roof deck plate of TK 77. NCR disposition details including corrective actions were also provided. TMEP also confirmed that there are no recurring issues of any consequence. No further information was required.
Observation 6 - Review of responses to IR 6 (TK75, TK79 and TK80 tank drawings)
Date & time of visit: 2022-07-07 11:00
Observation 7 - Review of response to IR 7 (Documentation for two welds/each of TK77, TK79, TK80)
Date & time of visit: 2022-07-07 13:00
Documentation requested for the two welds selected for each of tanks TK77, TK79 and TK80 was provided on 11 July 2022. Refer to Observation "Day 2" welds selection and the subsequent IRs. No further clarification was required for this IR.
Observation 8 - Review of response to IR 21 (TK95 dike concrete paving)
Date & time of visit: 2022-07-07 14:00
TMEP provided documentation regarding the slope paving at tank TK95 (i.e., CWA 204 Tank 95 Slope Paving Pour #14). CER inspectors noted that the slope paving documentation is specific to Pour #14, while the slope comprises numerous pours. The information provided appears to confirm that the slope is installed in accordance with designs submitted and approved by the Commission of the CER under the Burnaby Terminal Variance; however, further confirmation is required regarding concrete thickness and whether slope Pour #14 documentation is representative of all pours comprising the slope along TK95/97. (IR 30-a). TMEP provided "Secondary Containment" documentation containing permanent shoring drawings for a number of tanks, including TK95 (downloaded from Sharepoint Folder #6 - Tank Slope Paving Documentation). However, the drawings do not demonstrate whether the TK 95 slope paving has been installed in accordance with designs submitted to the CER. CER inspectors require further information from TMEP confirming its as-built concrete slope paving for TK95 (CWA 204) (IR 30-b).
Observation 9 - Review of response to IR 19 (Tank welding electrodes storage)
Date & time of visit: 2022-07-06 15:00
TMEP provided the Storage and Care of Welding Consumables procedure (TMEP Document #: 10090191-01-13283-LG-LM00-QA-PRO-0030 R0) as requested. The procedure confirms that low hydrogen (low strength) E7018/E8018, and stainless steel and nickel type electrodes are required to be stored at 250 deg. F and have a maximum exposure time of 4 hrs. No further information was required.
Observation 10 - Day 3
Date & time of visit: 2022-06-30 08:30
Observation 11 - Review of responses to IR 12 (Tank TK77 welds V14A and 18H11A)
Date & time of visit: 2022-07-11 22:00
Observation 12 - Review of responses to IR 10 (Tank TK79 welds V10A and 4H8C)
Date & time of visit: 2022-07-12 08:00
Observation 13 - Review of responses to IR 22 (TK80 welds V14C and V16B)
Date & time of visit: 2022-07-12 13:03
Observation 14 - Review of response to IR 20 (TK97 NDE Tech Certs)
Date & time of visit: 2022-07-13 08:00
The Non-Destructive Examination (NDE) Technician Certificates who performed the Phased Array Ultrasonic Testing (PAUT) on TK97 during the inspection, were provided by TMEP and reviewed. Two technicians are certified CAN/CGSB-48.9712-2014 PAUT Level II and Level III, respectively. No further information was required.
Observation 15 - Review of response to IR 13 (TK97 Weld Parameter Verification)
Date & time of visit: 2022-07-13 13:00
Observation 16 - Review of responses to IR14 - IR 18
Date & time of visit: 2022-07-14 08:00
The following documentation was provided by TMEP in response to IR 14 - IR 18:
Observation 17 - Review of response to IR 25 (Verification of new fire water reservoir volume)
Date & time of visit: 2022-07-11 09:00
TMEP provided documentation in response to IR 25 regarding its verification of the new as-built fire water reservoir volume. TMEP's reply reiterated the Burnaby Terminal Fire Protection Design Basis, which restates the usable working capacity of 6000 m3 (this coincides with information on file with the CER under the Burnaby Terminal Variance Application); however, CER inspectors requested from TMEP information on how it verifies that the constructed fire water reservoir volume is in accordance with the intended design. TMEP also provided a "FW Reservoir" document (from Sharepoint Folder #10) containing various fire water reservoir drawings showing modifications such as a concrete chamfer, mechanical anchoring details, and liner QC checks. CER inspectors interpret that the FW Reservoir document pertains to design modifications to the fire water reservoir which address leaks detected during reservoir commissioning in TB-KLTP-NCR-0199 . Information demonstrating TMEP's verification of the as-built fire water reservoir volume is not apparent in TMEP's response to IR 25. Therefore, CER inspectors require further information on the matter (IR 33)
Observation 18 - Review of response to IR 11 (Explanation of dike overflow)
Trans Mountain provided its response to IR 11 regarding an explanation of the functioning of its installed dike overflow system as presented in designs under Condition 24. TMEP reaffirmed the functioning of the dike overflow path as presented under Condition 24. In a scenario involving stormwater/oil overflow over the top of the berms, the overflow would be captured via open ditching at the downhill toe of the berm, and directed to the Tertiary Containment to prevent spilled oil from leaving the terminal. CER inspectors agree with TMEP's interpretation and observed evidence during the inspection that parts of the system were installed per the Condition 24 design, however further confirmation is requested from TMEP that the installed spill overflow control system will be completed in accordance with the design presented to the CER under Condition 24 (IR 32).
Observation 19 - Review of response to IR 23 (TB-KLTP-NCR-0220)
Date & time of visit: 2022-07-26 14:00
TMEP provided hardcopy documentation with information regarding the NCR 220 as requested by the CER inspectors (i.e., "NCR-320-BT-CWA 214 Portal - Anchors at East Wing Wall Failed to Meet the Required Proof Testing of Ground Anchors" - TMEP Document #TB-KLTP-NCR-0220 R1). The documentation states that for anchors R5-A03, R4-A04 and R4-A05 which did not meet the proof testing requirement, the proposed solution was to drill new anchors beside the mentioned anchors and continue to use the tremie grout method, instead of pressure grout the rest of the anchors. The documentation includes the test results for the new anchors R4-R04, R4-R03 and R4-R05. However, a final outcome of the proposed disposition and whether this was successful or not, was not included. (IR 35)
Observation 20 - Review of responses to IR 26 (Pipe welding)
Date & time of visit: 2022-07-27 11:00
TMEP provided hardcopy documentation regarding the NPS 30 pipe welding as requested during the inspection (Refer to Observation "Day 2 - IR 26"). This included: a) Piping welder qualification TMP-009 and TMP-006. The welders were tested and qualified for WPS-KIC-1 as per Welder Performance Qualification (WPQ) forms provided. It was noted that WPQs were revised, but it is unclear what was included in the new revisions in comparison with the previous versions. Further information is required. (IR 37-a) Welder TMP-006 CWB W47.1 certificate for manual welding expired on 13 February 2022 and for Semi-Automatic welding on 13 October 2021. Further clarification is required. (IR 37-b) CWB W47.1 certificates for welder TMP-009 were not provided. (IR 37-c) b) Piping weld traveler KLTP-FRM-WELD-4.07.02 Rev. 7 form for CWA 218 tank area and the isometric weld map (i.e., 30-CO-2474-A1, dwg. BB00-MI-CO-2474-12) c) Welding Procedure Specifications (WPS) KIC-1 and Welding Procedure Datasheet (WPDS) KIC-1 The information from the pipe traveler form KLTP-FRM-WELD-4.07.02 Rev. 7 for CWA 218 area (weld # FW-101), was reviewed against the isometric weld map, WPS KIC-1 Rev. 3 and the WPDS KLTP-WPDS-KIC-1. No further information was required regarding these forms. d) Welding Parameter Records from the month of June for welders TMP-006 and TMP-009. Forms KLTP-FRM-WLD-4.02.02 Rev. 2 - weld activity 01-13283-BB00-MI-CO-2491-11 FW106 for welders TMEP 006 and TMEP-009 included the welding parameters verification and acceptance as per WPS-KIC-1. No further information was required regarding the welding parameter records. e) Extra documentation This information was not requested during the inspection. The qualifications of the Metalogic Non-destructive Examination (NDE) technicians performing the pipe weld inspection, was not provided as requested. This information remains outstanding. (IR 37-d)
Observation 21 - Review of responses to IR 28
Date & time of visit: 2022-08-17 15:00
TMEP provided clarification regarding its document revision numbers and Contractor document revision numbers. TMEP confirmed that for both requests a) and b), TMEP document number Rev. 2 is Contractor document Rev. 1. TMEP confirmed that the supporting Procedure Qualification Record (PQR) 14148 for Welding Procedure Specification (WPS) WPS-EG72T-G indicates that the WPS was qualified on 1.25" plate in the normalized condition with a heat input of 432.3 KJ/in. This was verified in WPS-EG72T-G. TMEP also confirmed that it has requested that Horton CBI revise and re-submit the WPS and the Welding Procedure Data Sheet (WPDS) to show a heat input maximum of 432.3 KJ/in for normalized plate with a thickness of 0.625" to 2.500". New revisions of the WPS and WPDS are required to be provided to show that they have been updated. (IR 38)
Observation 22 - Review of responses to IR 30
Date & time of visit: 2022-08-17 16:00
TMEP confirmed that the hardcopy information provided for the slope paving at tank TK-95 (pour #14) is representative of the reminder of the pours comprising CWA 204. TMEP also confirmed that the minimum installed thickness for the slope paving in CWA 204 is 100mm, it is achieved by using steel beams for formwork that are 100mm thick and the actual concrete thickness is verified as part of the post-pour inspection. No further clarification was required regarding this IR.
Observation 23 - Review of response to IR 32
Date & time of visit: 2022-08-17 11:00
TMEP confirmed that spill overflow control system will be completed as described in Appendix B2 of condition 24 filing and noted that BB00-SK007 demonstrate overflow paths as per the IFC design. No further clarification was required regarding this IR.
Observation 24 - Review of response to IR 29
Date & time of visit: 2022-08-18 09:00
TMEP confirmed that the information provided in the Technical Conference meeting record was incorrect regarding material grades for shell ring 3 as this material was always intended to be SA516-60N and the selected thickness of the material grade A516-60N plate was calculated by the Tank Manufacturer using the appropriate design stress values listed in API 650. This information should be updated in Table A-1 of the 31 March 2020 Technical Conference meeting (C05555-1) (IR 39)
Observation 25 - Review of response to IR 27
Date & time of visit: 2022-08-18 11:00
Following-up on the response to IR 27. TMEP provided internal process documents IR27-01-13283-TB-BB00-PR-RFI-0002.pdf and IR27-MOC22928.pdf in support to the decision to remove tank TK-110. No further clarification is required regarding this IR.
Observation 26 - Review of response to IR 33
Date & time of visit: 2022-08-18 13:00
TMEP confirmed that the fire water reservoir volume is verified post-construction using laser scanning survey technology. TMEP provided an as-built survey sketch confirming the usable volume (capacity) of 6923.7 m3. No further clarification was required regarding this IR.
Observation 27 - Review of response to IR 35
Date & time of visit: 2022-08-18 14:00
TMEP confirmed that the proof testing determined that the newly installed R4-R03, R4- R04, and R4-R05 anchors met the design load requirements. TMEP has accepted both the anchor proof test results and the anchor grout compressive strength test results and the TB-KLTP-NCR-0220 was closed out and confirmed that it will be reported to the CER as closed in the August 2022 Condition 105 filing. No further clarification was required regarding this IR.
Observation 28 - Review of responses to IR 34
Date & time of visit: 2022-08-18 15:00
a) TMEP confirmed that MTRs are reviewed and accepted by the Tank designer, Horton CBI. TMEP reviews a sampling of MTRs during construction and TMEP's engineering and QA personnel review and accept the data book that includes all MTRs and sign the cover page. b) The documents provided in the response to this IR were reviewed against the MTRs provided for welds V14A /18H11A, V10A / 4H8C and V14C / V16B in the responses to IR 10, IR 12 and IR 22. The documents confirm that the shell plates used for these welds match the MTRs previously provided. c) TMEP confirmed that TMEP representatives have witnessed welder qualification testing in accordance with TMEP-MT3052 Section 11.0 and the witnessing activity is recorded by TMEP in Joining Program Welding Specialist reports. d) TMEP clarified that welder's #9 qualification for WPS-ENi4/OK 10.70 machine welding referenced in the TK77 documentation is an additional qualification to other SAW welding procedure. No further clarification was required regarding this IR.
Observation 29 - Review of response to IR 36
Date & time of visit: 2022-08-16 14:30
TMEP clarified that according to its Inspection and Test Plan (ITP) - which requires one hardness determination to be made for every third groove weld and for every third butt weld, if any, at nozzles and manways and one hardness determination to be made for every second vertical butt weld - the weld V17A on TK-97, was not selected for hardness testing. No further clarification is required regarding this IR.
Observation 30 - Review of responses to IR 37
Date & time of visit: 2022-08-16 14:15
TMEP explained the rationale for issuing different revisions of the welder Performance Qualifications (WPQs) for welders TMP-006 and TMP-009. TMEP provided the current CSA W47.1 certification for welder TMP-006 and the certification for welder TMP-009, as well as certifications for the Metalogic NDE technician which were verified (i.e., NRCan) as being valid. No further clarification was required regarding this IR.
Observation 31 - Review of response to IR 31
Date & time of visit: 2022-08-19 11:00
TMEP confirmed that Horton CBI Welding Parameter Verification report template does not include form fields to document joint geometry, joint cleaning, pre-heat temperature, interpass temperature, or interpass grinding and cleaning, but it does not mean that these variables are not assessed during welding inspection. It was also confirmed that TMEP inspectors, TMEP Quality Assurance personnel, and TMEP Joining Program Welding Specialists do assess interpass temperature and interpass grinding and cleaning during welding inspection activities. Also, TMEP personnel have not identified any instances of non-conforming interpass temperatures or interpass grinding and cleaning practices at Burnaby Terminal on the tanks being erected by Horton CBI. It is noted that Trans Mountain Expansion Project Horton CBI - ITP - Field Inspection & Test Plan Field Erected Tanks, TMEP Document #: 10090191-01-13283-TB-BB00-ME-ITP-0001 R 3, HCBI Document #: 241091-000-QA-CK-00001 which was previously submitted to the CER, lists the activities related to the verification of welding parameters. Thus, according to activity #25.b which is related to the preheat and interpass temperature monitoring, these parameters are required to be verified randomly on 10% of production welders once per week and document, and recorded by the HCBI in the Welding Parameter Verification Form. Based on TMEP response to IR 31 and the ITP document referenced above, it remains unclear whether the interpass temperature and interpass grinding and cleaning assessments results are documented each time these verifications are conducted. It is also unclear where is the interpass temperature verification recorded and why it is not recorded on the HCBI welding Parameter Verification Form as required by the ITP. Also, the assessment results for vertical seam 11A were not provided. Further information is required. (IR 40)
Observation 32 - Review of response to IR 24
Date & time of visit: 2022-08-22 10:00
TMEP provided the fire truck access plan – drawing IR24-GC[1]01-13283-GG-0000-STANTECENG-GC-0053-01-13283-BB00-CE01.pdf which includes the new access roads to be designed in compliance with BCBC DIV B Part 3.2.5.6. TMEP also stated that since all tanks have been equipped with fixed protection system as per NFPA 11, then irrespective if the design meets 4.3.2.4 (1) and 4.3.2.4 (2) (i.e., BCBC part 3.2.5 requirement), the design meets the requirement of section 4.3.2 of BCFC. TMEP committed to verify the roads widths and turning radius information by means of survey and as-built drawings prior to commissioning. No further clarification was required regarding this IR at this time.
Observation 33 - Review of response to IR 38
Date & time of visit: 2022-08-29 16:00
TMEP submitted updated revision of the Welding Procedure Specification (WPS) WPS-EG72T-G (TMEP Document #: 10090191-01-13283-GG-0000-QA-PRO-0009 R2A) and Welding Procedure Data Sheet (WPDS) HCBI-WPDS-EG72T-G (TMEP Document #: 10090191-01-13283-GG-0000-ME-DAS-0009 R0A) including the heat input maximum of 432.3 Kj/in for normalized plate to 1.43" - the maximum thickness of normalized plate on this project. TMEP confirmed that both WPS ans WPDS have been reviewed and accepted by its welding SMEs. Approval signatures will be included on the cover pages of the updated Condition 111 Joining Program filing. No further clarification was required regarding this IR.
Observation 34 - Review of response to IR 39
Date & time of visit: 2022-08-29 16:45
TMEP provided a revised Storage Tank Shell Plate Details - Table A-1 indicating material grade A516-60 for shell course 3 of tanks TK-78 and TK-79. No further clarification was required regarding this IR.
Observation 35 - Review of response to IR 40
Date & time of visit: 2022-08-30 22:00
TMEP considers that the documentation provided to the CER inspectors adequately documents interpass temperature and interpass grinding and cleaning assessment results. In support to its statement, TMEP indicated the previous response to IR 31, which confirms that TMEP Joining Program Welding Specialists assess the interpass temperature and the interpass grinding and cleaning during welding inspection activities. TMEP further indicates that the HCBI Welding Parameter Verification Report template includes notes requiring the verification of the interpass temperature and interpass grinding and cleaning and has acceptance signature fields in the footer. Regarding the request for interpass temperature and interpass grinding and cleaning assessment results for vertical seam 11A TK-97, TMEP refers back to the HCBI Welding Parameter Verification Report provided to the CER inspectors indicating that this includes TMEP Welding Inspector's review and acceptance of the report. TMEP also provided the Facilities Field Welding Audit Report 20220531-TMEP-TK-BB_T-WELD-ADT-WW-00054 of 31 May 2022 which was prepared for tank TK-97. The interpass temperature and the interpass grinding and cleaning assessment results demonstrating compliance with the WPS were recorded on the audit report. According to section 12.1 of the TMEP-MT3052, the frequency of internal quality audits has been established by the tank manufacturer and approved by TMEP. The CER inspectors note that the frequency of field welding audits is not confirmed to be similar to the frequency of welding parameter verification specified by the ITP. According to TMEP Document #: 10090191-01-13283-TB-BB00-ME-ITP-0001 R3 (ITP), Activity No. 25(a), the Preheat & Interpass Temperature Monitoring are required to be conducted randomly on 10% of production welders once per week and have to be documented (referencing controlling document TMEP-MT3052 - Storage Tank Welding and Non-Destructive Testing Specification, sections 8.1 and 12.1). The Inspection and Test Plan (ITP) also indicates the Welding Parameter Verification Report as the recording document for activity no. 25(a). TMEP's document TMEP-MT3052 section 12.1, establishes general requirements including suitable measures for measuring interpass temperatures utilized for compliance with the WPS, and also establishes requirements for making documentation of compliance verifications. The CER inspectors note that as shown in the current revision of the HCBI Welding Parameter Verification Report template, the interpass temperature is required to be checked for conformance with the Welding Procedure Specifications (WPS) at the frequency specified in the ITP. The results of welding parameters verification are recorded on the report and accepted and signed off by the HCBI inspector, the KLTP quality representative and the TMEP representative. The CER inspectors determined that the current revision of the HCBI Welding Parameter Verification Report template does not include a field for the welding interpass temperature measurements to be appropriately recorded, subsequently to demonstrate compliance with the WPS, and to align with the requirements of TMEP's ITP and TMEP-MT3052.
Compliance tool used: Notice of Non-compliance (NNC)
Regulatory requirement:
Relevant section(s):
Company action required:
1. TMEP to make changes to the current revision of the HCBI Welding Parameter Verification template (document 220369-000-WS-CK-00001 Rev 0) to include an additional field for recording the interpass temperature measurements taken during the welding inspection process. 2. TMEP to provide a copy of the new revision of the HCBI Welding Parameter Verification template.
Due date: 2022-09-23
Date closed: 2022-09-26 Note: the date closed is the date that the inspector completed their review of the company corrective actions for adequacy and determined that no further actions are required.
Reason closed: Requirement met
Compliance achieved: Yes
Identified non-compliances to company plans or procedures are non-compliances either to:
- the condition of an authorization document that requires the implementation of that plan or procedure; or
- the relevant section of the regulations that requires implementation of that plan or procedure including those sections that require implementation of plans or procedures as a part of a Program
